Baykeeper v. Hanson Aggregates Mid-Pacific, Inc. et al

Filing 5

STIPULATION AND ORDER RESETTING CMC re 4 Stipulation filed by Hanson Aggregates LLC, Hanson Aggregates Mid-Pacific, Inc.. Signed by Judge Edward M. Chen on 5/25/11. (bpf, COURT STAFF) (Filed on 5/25/2011)

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DOWNEY BRAND LLP

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DOWNEY BRAND LLP
NICOLE E. GRANQUIST (Bar No. 199017)
621 Capitol Mall, 18th Floor
Sacramento, CA 95814-4731
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Defendants
HANSON AGGREGATES MID-PACIFIC,
INC. and HANSON AGGREGATES LLC
Jodene Isaacs (Bar No. 226895)
Christopher Sproul (Bar No. 126398)
ENVIRONMENTAL ADVOCATES
5135 Anza Street
San Francisco, California 94121
Telephone: [phone])
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff
BAYKEEPER

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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BAYKEEPER,
Plaintiff,

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v.

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Case No. C 11-01722 EMC
STIPULATION EXTENDING TIME FOR
CASE MANAGEMENT CONFERENCE;
[PROPOSED] ORDER THEREON

HANSON AGGREGATES MIDPACIFIC, Inc. and HANSON
AGGREGATES LLC.

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Defendant.

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Plaintiff, Baykeeper, and Defendants, Hanson Aggregates Mid-Pacific, Inc. and Hanson

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Aggregates LLC (collectively “Hanson”), (collectively, the “Parties”) hereby stipulate to extend

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the time for the initial Case Management Conference by forty-five (45) days. The Case

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Management Conference is currently scheduled for July 20, 2011. With this initial extension, the

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Case Management Conference would be scheduled on or after September 3, 2011.
1160437.1

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STIPULATION EXTENDING TIME FOR CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

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The Parties are engaged in substantive settlement discussions, and wish to avoid the

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potentially unnecessary cost of preparing litigation-related pleadings and documents in the event

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the parties are able to reach informal resolution of the matter.

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Baykeeper and Hanson submit this stipulation pursuant to Local Rule 6-2(a), which allows

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the filing of a stipulation, and conforming to Civil L.R. 7-12, requesting an order changing time

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that would affect the date of an event or deadline already fixed by Court order.

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NOW THEREFORE, for the reasons set forth above, the Parties hereby stipulate, and

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respectfully request, that the Court enter an order extending the deadline for the initial Case

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Management Conference by forty-five (45) days, and scheduling the Case Management

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Conference for a date on or after September 3, 2011.

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DOWNEY BRAND LLP

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RESPECTFULLY SUBMITTED,
DATED: May 24, 2011

DOWNEY BRAND LLP

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By:

/s/ Nicole E. Granquist
NICOLE E. GRANQUIST
Attorney for Defendants

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DATED: May 24, 2011

ENVIRONMENTAL ADVOCATES

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By:

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/s/ Jodene Isaacs
JODENE ISAACS
Attorney for Plaintiff
BAYKEEPER

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1160437.1

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STIPULATION EXTENDING TIME FOR CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

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[PROPOSED] ORDER

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Good cause appearing, and based on the stipulation of the parties,

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IT IS HEREBY ORDERED that the Case Management Conference currently scheduled

5/25/11
DATED: ___________________

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By:
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ERED
O ORD D
IT IS S
DIFIE
AS MO

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A

H

ER

LI

RT

FO

NO

Hon. EdwardeM. Chen
h n
r M. C
U.S. District Court,dNorthern District of California
ge Edwa
Jud

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DOWNEY BRAND LLP

S DISTRICT
TE
C
TA

RT
U
O

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IT IS SO ORDERED.

R NIA

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S

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for July 20, 2011 is vacated, and the Case Management Conference is rescheduled to occur on
Sept. 9
in Courtroom 5, 17th Floor.
9:00
___________________, 2011 at _____ a.m./p.m.

UNIT
ED

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D IS T IC T O
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1160437.1

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STIPULATION EXTENDING TIME FOR CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER